CNRO-2003-00063, Arkansas, Unit 1 - Requests for Relief from ASME Section XI Volumetric Examination Requirements

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Arkansas, Unit 1 - Requests for Relief from ASME Section XI Volumetric Examination Requirements
ML033430465
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 12/02/2003
From: Krupa M
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2003-00063
Download: ML033430465 (34)
v • d • e


Text

{{#Wiki_filter::' i I. __6__ Entergy Entergy Operations, Inc. 1340 Echelon Parkway Jackson, MS 39213-8298 Tel 601 368 5758 Michael A. Krupa Director Nuclear Safety & Licensing CNRO-2003-00063 December 2, 2003 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy Operations, Inc. Requests for Relief from ASME Section Xl Volumetric Examination Requirements Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from the requirements of ASME Section Xl pertaining to volumetric examination of pressure-retaining welds for Arkansas Nuclear One, Unit 1. In several locations, the required coverage cannot be obtained due to interference or geometry. Relief Requests ANO1-ISI-001, -002, -003, and -004 are provided in Enclosures 1 - 4, respectively. Entergy requests that the NRC staff grant the enclosed relief requests on or before December 2, 2004. This letter contains no commitments. Should you have any questions regarding these requests, please contact Guy Davant at (601) 368-5756. Very truly yours, MAK/GHD/bal

Enclosures:

1. Relief Request ANO1-ISI-001
2. Relief Request ANO1-lSI-002
3. Relief Request ANO1-lSI-003
4. Relief Request ANO1-ISI-004 Nq

CNRO-2003-00063 Page 2 of 2 cc: Mr. W. A. Eaton (ECH) Mr. J. S. Forbes (ANO) Mr. R. W. Deese, NRC Senior Resident Inspector (ANO) Dr. B. S. Mallett, NRC Region IV Regional Administrator Mr. J. L. Minns, NRR Project Manager (ANO-1)

ENCLOSURE 1 CNRO-2003-00063 RELIEF REQUEST ANOI-ISI-001

ENTERGY OPERATIONS, INC. RELIEF REQUEST ANOI -ISI-001 ASME COMPONENTS ComponentslNumbers: Pressurizer and steam generator nozzles listed in Table I ASME Code Class: I

References:

1. ASME Section Xl 1992 Edition, Table IWB-2500-1
2. ASME Section XI 1980 Edition with the Winter 1981 Addenda
3. Letter from the NRC to Entergy Operations, Inc.,

Evaluation of Entergy Operations, Inc. Request for Authorization to Update Inservice Inspection Programs to the 1992 and Portions of the 1993 ASME Boiler and Pressure Vessel Code, Section Xl for Arkansas Nuclear One, Units I and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3 (TAC Nos. M94472, M94471, M94454, M94473, and M94488), dated December 12, 1996

4. ASME Code Case N-460 - Alternative Examination Coverage for Class I and 2 Welds, Section Xl, Division 1 Examination Category: B-D Item Numbers: B3.110, B3.130, 83.140 Unit I Inspection Arkansas Nuclear One Unit 1 - third (3rd) 10-year interval Interval Applicability:

II. ASME CODE REQUIREMENT(S) ASME Section Xl, Table IWB-2500-1, Examination Category B-D, Item 13.110 requires essentially 100% volumetric examination of the pressurizer nozzle-to-vessel welds. ASME Section Xl, Table IWB-2500-1, Examination Category B-D, Items B3.130 and B3.140 require essentially 100% volumetric examination of the steam generator nozzle-to-vessel welds and inner radius sections. ASME Code Case N-460 allows a reduction in coverage for Class 1 and 2 welds due to interference or geometry as long as the overall coverage is greater than 90%. Page 1 of 12

Ill. RELIEF REQUESTED Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage when performing volumetric examinations of the components identified in Table 1, below. Table I Limited B-D Examinations Item # Item ID Description Coverage (%) Reason for Limitation 83.110 05-012 Pressurizer relief valve 45 Nozzle Configuration nozzle-to-vessel weld 83.110 05-013 Pressurizer spray 38 Nozzle Configuration nozzle-to-head weld B3.130 03-008 Steam generator outlet 40.4 Nozzle Configuration nozzle-to- head weld (Reactor and Support Skirt Coolant Pump D cold leg) B3.140 03-009 Steam generator outlet 90.7 Steam Generator nozzle-to-lower head inner Support Skirt radius (Reactor Coolant Pump C cold leg) IV. BASIS FOR RELIEF During the ultrasonic examination of the pressurizer and steam generator nozzle welds (ID #s 05-012, 05-013, and 03-008) and the inner radius section (ID #03-009) listed in Table I above, 100% coverage of the required examination volume could not be obtained due to nozzle configuration. Specifically for the nozzle welds, effective volumetric examination can only be performed from the shell side of the welds. In addition, the steam generator support skirt limits accessibility to the steam generator outlet nozzle inner radius sections. Examination coverage calculation sheets provided in the attachment of this relief request show the nozzle configuration, limitations, and beam plots of the different examination angles used. The weld volume was scanned using 00, 450, 60°, and 70° beam angles. Nozzle inner radius limitations of ID #03-009 are caused by the ratio of the nozzle outside diameter (OD) to the vessel thickness. When the nozzle OD is small in relation to vessel thickness, more coverage can be obtained when scanning from the vessel side. Conducting examinations from the nozzle boss and OD blend is not practical, due to the complex beam angles and skews that must be calculated and then maintained during manual scanning in order to achieve an effective examination. To maximize coverage, the volume was scanned using 60° and 70° beam angles. Radiography is not practical because of the geometry of the components, which prevents proper placement of the film and exposure source. To perform the Code-required examination would require modifying and/or replacing the components. The examinations performed on the subject items, in addition to the examination of other Page 2 of 12

nozzle-to-vessel welds and inner radius sections contained in the program, would detect generic degradation, if it existed, demonstrating an acceptable level of integrity. V. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined the subject components to the extent practical and will continue to perform pressure testing on the pressurizer as required by the Code. VI. CONCLUSION 10 CFR 50.55a(g)(6)(i) states: The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Due to design configuration, it is impractical to obtain greater than 90% coverage on ID #s 03-008, 05-012, and 05-013 and 100% of the inner radius section of ID #03-009. To obtain the required coverage would necessitate modifying and/or replacing components. Examinations performed on the subject components, in addition to examinations of similar welds and inner radius sections contained in the program, would detect generic degradation, if it existed, thereby demonstrating an acceptable level of integrity. Therefore, Entergy requests the NRC staff authorize the proposed alternative pursuant to 10 CFR 50.55a(g)(6)(i). Page 3 of 12

ATTACHMENT RELIEF REQUEST AN0I -ISI-001 EXAMINATION COVERAGE CALCULATION SHEETS Page 4 of 12

0 Entergy EXAMINATION COVERAGE CALCULATION SHEET Attachment #: A l ANO1 l3 ANO 2 0O Grand Gulf 1 Rhver Bend 03 Waterford 3 Component ID: 03-008 Report No.: 1981SlUT060 Material Type: CS clad Vessel Weld T: -9.0' Angles Used: 450° 600 700 S - % V. 0° L NOTES: I The 112T dimension on each side of the weld is for Class I vessel volume. 2 This Is an approximate percent of the examination volume forwhich coverage was obtained. 3 The plot shown is a representation of the actual profile and not to scale. 45Shear-wave Scan Directions LII No Coverage Direction #1 Direction #2 60 Shear-wave scan directions D No Coverage m//1 Direction #1 m ", Direction #2 Page o1141 Page 5 of 12 

   -t-Erl tWegy            EXAMINATION COVERAGE CALCULATION SHEET I                                                                                                                I 70' Shear-wave Scan directions ALID   r-tst--{,4    -  ALc..ApJ4L~e1
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F-1 No Coveragee Direction #1 Direction #2 No Coverage lllllllllllll Direction #3 lllllllllllll Direction #4 Required scan coverage: Weld -30.2 %. Base material head side - 68.7%, Base material nozzle side -22.3% TOTAL EXAM VOLUME OBTAINED: 40.4% COMMENTS: Steam generator cold leg nozzle to lower head. This is primarily a single sided examination. Scans were performed from the nozzle side to supplement coverage with minimal effect. The support skirt prevented scanning around the total circumference of the nozzle. The cumulative coverage estimation Includes the code required base metal coverage adjacent to the weld and the factor of multiple angles from multiple directions. fRsJP A4 Page 6 of 12

NOV-20-2003 08:36 FRW: I U: ER.Mmstpq V: d-1.5 

         -e                 EXAMINATION COVERAGE CALCULATION SHEET Attachmont#: A                      l  AN0ol       l    !AN2       Gnd Gulfrd3 13nmdOU1      lRiverpmnd Component ID: 03-009           Report No.: 190161UT062lM            Material Type: CS ttcf Vessel Weld T: -9.0'           Angles Used: 5.e 604 704 S - %V NOTES:

mThe examination volume for Cluas I nozzles Includes Y" radial distance Into the nozzle from the inside radius (see figure IWB.500-7(b). 2 This Is an approxImate percent of the examination volume for which coverage was obtained. 3 .Te plot shown Is a roproseotatlon of tho actual profile and not to scale. 45'Shear-wave Scan Plrections _~~~~~~~~~~~~~~~~- ArA/ c W, 11 No Coverage Direction #1 iDrectlon #2 600 Shear-wave scan directions X~~~r~~~roufa on co0.oa9 E No Coverage Direction #1 EMEN"' Direction #2 I Page 7 of 12 fd

NOV-20-2003 88:37 FROM': I U:qjjq U: e I.%Ente~x EXAMINATION COVERAGE CALCULATION SHEET 7D- Shear-wave Scan diections g~~~~- /07a e-l L] No Coverage Direction#1 D1irection2 Illustration of support skirt IlmRatlon 15 ge 4-7 I I3 X 6t oe FII No Coverage Direction #3 EIiDI Dlrection *4 Required scan coverage obtained: CUMULATIVE TOTAL EXAM VOLUME OE3TAINED: 90.7% COMMENTS: Steam generator cold leg nozzle to lower head. This Is primarily n single sided examination. Scans were performed from the nuzzlo side to supplement coverage with minimal effect. The support skirt prevented scanning around the total circumference of the nozzle. The cumulative coverage estimation Includes a summary of the scans wth multiple angles frem the accessible directions. II i IYar II Page 8 of 12 I 

    '-a7&tergy          EXAMINATION COVERAGE CALCULATION SHEET Attachment #: A                     V ANO1         I0 AN02         I0 Grand Gulf    C River Send  0 Waterford3l Component ID: 05-012          Report No.: 1981SIUTOIO. 030. 031. 038            Material Type: CS dad Vessel Weld T: -5.0'          Angles Used: 45°0 60°' 70° S - 1 2 V. 0gL NOTES:

1 The 112T dimension on each side of the weld Is for Class I vessel volume. 2 This Is an approximate percent of the examination volume forwhich coverage was obtained. . 3 The plot shown Is a representation of the actual profile and not to scale. No Coverage Direction #i ENEEM" Direction #2 WNo Coverage Direction #1 Direction #2 Page 9 of 12

I eEntey EXAMINATION COVERAGE CALCULATION SHEET LI No Coverage N Direction #1 Direction #2 No Coverage lllllllllllll Direction #3 Direction #4 Required scan coverage obtained: Weld - 18.6  %, Base material head side - 92.9  %, Base material nozzle side -22.1% TOTAL EXAM VOLUME OBTAINED: 45% COMMENTS: Pressurizerspray nozzle to head weld. This Is a single sided examination. The cumulative coverage estimation Includes the code required base metal coverage adjacent to the weld and the factor of multiple angles from multiple directions. Coverage Illustrations depict added scans with .5 diameter transducers to increase coverage, 1 diameter transducers were used for the primary examination. Page 10 of 12

l - Entergy EXAMINATION COVERAGE CALCULATION SHEET l Attachment #: A Ia ANOl lI ANO2 I 0 GrandGulf I. RiverBend I0 Waterford3l Component ID: 05-013 Report No.: 1991SIUT018. 019 Material Type: CS clad Vessel Weld T: -5.5' Angles Used: 450° 60° 70° S - MYV. 0° L NOTES: 1 The 1/2T dimension on each side of the weld is for Class I vessel volume. 2 This is an approximate percent of the examination volume for which coverage was obtained. 3 The plot shown Is a representation of the actual profile and not to scale. D~ No Coverage Direction #1 Direction #2 I I II II i II I I I No Coverage Direction #1 X\E\1\~ Direction #2 Page 11 of 12

I aEnter~gy EXAMINATION COVERAGE CALCULATION SHEET FI No Coverage Direction #1 ENNE, Direction #2 No Coverage IIIIIIHIIII1 Direction #3 l1llllllllllI Direction #4 Required scan coverage obtained: Weld -15.9 %, Base material head side - 65.7%, Base material nozzle side -32.5% TOTAL EXAM VOLUME OBTAINED: 38% COMMENTS: Pressurizer head to safety nozzle. This Is primarily a single sided examination. Scans were performed from the nozzle side to supplement coverage with minimal effectr The cumulative coverage estimation includes the code required base metal coverage adjacent to the weld and the factor of multiple angles from multiple directions. Coverage illustrations depict only one location of a complicated nozzle geometry. Page 12 of 12 

                                                                                                     . 1)

IZ4 V

ENCLOSURE 2 CNRO-2003-00063 RELIEF REQUEST ANOI -ISI-002

ENTERGY OPERATIONS, INC. RELIEF REQUEST ANOI-ISI-002 ASME COMPONENTS Components/Numbers: Pipe-to-valve welds listed in Table 1 ASME Code Class: 1

References:

1. ASME Section Xl 1992 Edition, Table IWB-2500-1
2. ASME Section Xl 1980 Edition with the Winter 1981 Addenda
3. Letter from the NRC to Entergy Operations, Inc.,

Evaluation of Entergy Operations, Inc. Request for Authorization to Update Inservice Inspection Programs to the 1992 and Portions of the 1993 ASME Boiler and Pressure Vessel Code, Section Xl for Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3 (TAC Nos. M94472, M94471, M94454, M94473, and M94488), dated December 12, 1996

4. Letter from the NRC to Entergy Operations, Inc.,

Risk-Informned Altemative to Certain Requirements of ASME Code Section Xl, Table IWB-2500-1, at Arkansas Nuclear One, Unit 1 (TAC No. MA2023), dated August 25,1999

5. ASME Code Case N-460 - Alternative Examination Coverage for Class I and 2 Welds, Section XI, Division 1 Examination Category: B-J Item Numbers: 89.11 Unit I Inspection Arkansas Nuclear One Unit I - third (3d) 10-year interval Interval Applicability:

II. ASME CODE REQUIREMENT(S) ASME Section Xl, Table IWB-2500-1, Examination Category B-J, Item B9.11 requires essentially 100% volumetric examination of the Class 1 pipe welds identified through the risk-informed process. ASME Code Case N-460 allows a reduction in coverage for Class I and 2 welds due to interference or geometry as long as the overall coverage is greater than 90%. Page 1 of 6

I Ill. RELIEF REQUESTED Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage (> 90%) when performing volumetric examinations of the components identified in Table 1, below. Table 1 Limited B-J Examinations Item ID Description Coverage (%) Reason for Limitation 24-024 21/2-inch pipe-to-valve weld 71.5 Pipe-to-Valve Configuration 25-031 1 1A/inch pipe-to-valve weld 61.2 Pipe-to-Valve Configuration IV. BASIS FOR RELIEF The subject welds are clad carbon steel and were examined to the maximum extent practical using the ultrasonic testing (UT) examination technique. However, Code-required coverage could not be obtained. A 70° shear wave and 70° RL wave were used to maximize coverage. These welds were examined prior to May 22, 2000 (mandatory implementation of ASME Section Xi Appendix Vil) using personnel that met the qualification requirements for performing UT in accordance with the 1992 Edition of ASME Section Xl, Appendix VII, 'Qualification of Nondestructive Examination Personnel for Ultrasonic Examination." Additionally, the personnel that performed the UT examinations had successfully completed the practical examinations of the Performance Demonstration Initiative (PDl) for the specific application areas. Examination coverage calculation sheets provided in the attachment of this relief request show the piping configurations, limitations, and beam plots. Welds 24-024 and 25-031 were selected for examination via a risk-informed process based on the NRC's safety evaluation for ASME Code Case N-560 (Reference 4). The degradation mechanism identified for both welds was thermal fatigue; therefore, Entergy conducted an assessment to determine the volume necessary to locate degradation caused by thermal fatigue. A description of the assessment process and its results as applied to these welds are discussed below. Thermal Fatigue Volume Assessment

1. The first step in the assessment process identifies whether or not the area to be examined is located in a horizontal run of piping connected to the secondary side of a steam generator. Since the industry has experienced cracking in such locations (in particular, the counterbore section of the pipe-side weld), the examination must capture the volume of interest. As such, partial coverage of the safe-end or nozzle is acceptable, but full coverage is required for the pipe-side of the weld heat affected zone (HAZ), including the pipe side counterbore.

In this case, the subject welds are not located on a horizontal run of piping connected to a steam generator. Page 2 of 6

2. The second step identifies whether or not the location is a 'pipe-to-pipe configuration. If so, the assessment investigates the presence of a counterbore - for example, the distance of the counterbore from the weld fusion line. If the counterbore is a fair distance (>1/2 inch) from the welded joint, then the multiplicative effect of stress concentration due to the welding process, counterbore discontinuity, and weld geometry are less than if the counterbore were in close proximity to the welded joint.

As such, the acceptable examination volume does not need to capture the counterbore for pipe-to-pipe joints, if the counterbore is at least 2inch from the edge of the weld fusion line. In this case, the subject welds are both pipe-to-valve welds rather than pipe-to-pipe welds.

3. For other pipe-to-component welds, the assessment process determines the extent of examination coverage taking into account not capturing the counterbore. In this situation, the process divides the area of concern into two parts: (1)the pipe side of the joint; and (2)the component side of the joint. There is sufficient evidence to assure that the dominate cracking will occur in the pipe side of the joint; therefore, limited coverage on the component side is acceptable.

As stated in #2 above, both welds are pipe-to-valve welds with no counterbore and received 100% coverage on the pipe-side of the weld. Based on the above assessment, the volume required to locate degradation due to thermal fatigue on a pipe-to-valve weld has been examined for the subject welds. VI. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined Welds 24-024 and 25-031 to the extent practical and will continue to perform pressure testing on the subject welds as required by the Code. VI. CONCLUSION 10 CFR 50.55a(g)(6)(i) states: The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Due to design configuration, it is impractical to obtain greater than 90% coverage on Welds 24-024 and 25-031. To obtain the required coverage would necessitate modifying and/or replacing components. Based on the assessment for thermal fatigue discussed above, the volume examined included that necessary to locate the expected degradation if it existed, thereby demonstrating an acceptable level of integrity. Examinations performed on the subject welds, in addition to examinations of similar welds contained in the program, would detect generic degradation, if it existed. Therefore, Entergy requests the NRC staff authorize the proposed alternative pursuant to 10 CFR 50.55a(g)(6)(i). Page 3 of 6

ATTACHMENT RELIEF REQUEST ANOI-ISI-002 EXAMINATION COVERAGE CALCULATION SHEETS Page 4 of 6 

 ~Entergy                 EXAMINATION COVERAGE CALCULATION SHEET Attachment #: A                        a ANO 1        0 AN02     l    Grand Gulf    0 R RerBend   l0 Waterord 3 Component ID: 24-024            Report No.: 1991SIUT047        Material Type: SS Pipe Diameter.: 2.5"            SchI T: .375'          Angie's Used:    7V0 S - 1 V . 70- RL 1%V NOTES:

I The .25" dimension on each side of the weld Is for non-risk Informed ISI, for risk Intormed ISI the exam volume will be determined by the risk informed program. 2 This Is an approximate percent of the examination volume for which coverage was obtained. 3 The plot shown is a representation of the actual profile and not to scale. F No Coverage Direction #1 X Direction #2 TOTAL EXAM VOLUME OBTAINED: 71.6 % COMMENTS:~~~~ 

                         ~     xmdet
                                ~~          ofgrto Sigesd pp ovav)             hseaiainwspromdpirt COMM ENTS: Single side exam due to configuration (pipe to valve). This examination was performed prior to the Section XI, Appendix Vil Implementation.

0,Lf Page 5 of 6

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 ,=-,-En t&9Y           EXAMINATION COVERAGE CALCULATION SHEET Attachment #: A                       A ANO1            0 ANO 2        0 Grand Gulf    0 RIver Bend 03 Waterford 3 Component ID: 25-031            Report No.: 1991S1UT045             Material Type: SS Pipe Diameter.: 1.5'            SchJT: ..2810             An! gle's Used:    70 S -I V, 700 RL '%V NOTES:

I The .25" dimension on each side of the weld Is for non-risk informed ISI, for risk informed ISI the exam volume will be determined by the risk Informed program. 2 This Is an approximate percent of the examination volume for which coverage was obtained. 3 The plot shown is a representation of the actual profile and not to scale. FLOxW ct:.'q- 

                                             ,Id's    letL
                                            - I       -1 111, -

UPSM$tE.M - 2: - -L Dz No Coverage Direction #1 Direction #2 TOTAL EXAM VOLUME OBTAINED: 61.2 % COMMENTS: Single side exam due to configuration (pipe to valve). This examination was performed priorto the Section XI, Appendix VIII Implementation. It'AICl~ c7_ Page 6 of 6

ENCLOSURE 3 CNRO-2003-00063 RELIEF REQUEST ANO1-1SI-003

ENTERGY OPERATIONS, INC. RELIEF REQUEST ANOI -ISI-003 ASME COMPONENTS Component/Number: Steam generator A upper shell-to-upper nozzle belt circumferential weld 03-047 ASME Code Class: 2

References:

1. ASME Section Xl 1992 Edition, Table IWC-2500-1
2. ASME Section Xl 1980 Edition with the Winter 1981 Addenda
3. Letter from the NRC to Entergy Operations, Inc.,

Evaluation of Entergy Operations, Inc. Request for Authorization to Update Inservice Inspection Programs to the 1992 and Portions of the 1993 ASME Boiler and Pressure Vessel Code, Section Xl for Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3 (TAC Nos. M94472, M94471, M94454, M94473, and M94488), dated December 12, 1996

4. ASME Code Case N-460 - Alternative Examination Coverage for Class 1 and 2 Welds, Section Xi, Division I Examination Category: C-A Item Numbers: C1.10 Unit I Inspection Arkansas Nuclear One Unit 1 - third (3d) 10-year interval Interval Applicability:

II. ASME CODE REQUIREMENT(S) ASME Section Xl, Table IWC-2500-1, Examination Category C-A, Item C1.10 requires essentially 100% volumetric examination of the pressure retaining welds. ASME Code Case N-460 allows a reduction in coverage for Class 1 and 2 welds due to interference or geometry as long as the overall coverage is greater than 90%. III. RELIEF REQUESTED Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage (> 90%) when performing volumetric examinations of the subject weld. See information in Table 1. Page 1 of 5

Table I Limited C-A Examination Item ID Description Coverage (°/,) Reason for Limitation 03-047 Steam generator upper nozzle 75.1 Nozzle-to-vessel belt-to-upper shell weld configuration IV. BASIS FOR RELIEF During the ultrasonic examination of Weld 03-047, 100% coverage of the required examination volume could not be obtained due to the configuration of the steam generator. Specifically, effective volumetric examination was limited by the nozzle belt taper. Examination coverage calculation sheets provided in the attachment of this relief request show the shell-to-nozzle belt configuration, limitations, and the beam plots of the different examination angles used. The volume was scanned using 450, 600, and 70° beam angles. Radiography is not practical because of the geometry of the component, which prevents proper placement of the film and exposure source. To perform the Code-required examination would require modifying and/or replacing the component. The examinations performed on Weld 03-047, in addition to the examination of other steam generator welds contained in the program, would detect generic degradation, if it existed, thereby demonstrating an acceptable level of integrity. V. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined Weld 03-047 to the extent practical and will continue to perform pressure testing on the weld as required by the Code. VI. CONCLUSION 10 CFR 50.55a(g)(6)(i) states: The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Due to design configuration, it is impractical to obtain greater than 90% coverage on Weld 03-047. To obtain the required coverage would necessitate modifying and/or replacing the component. Examinations performed on the subject weld, in addition to examinations of similar welds contained in the program, would detect generic degradation, if it existed, thereby demonstrating an acceptable level of integrity. Therefore, Entergy requests the NRC staff authorize the proposed alternative pursuant to 10 CFR 50.55a(g)(6)(i). Page 2 of 5

ATTACHMENT RELIEF REQUEST ANOI -ISI-003 EXAMINATION COVERAGE CALCULATION SHEETS Page 3 of 5

lFnatergy EXAMINATION COVERAGE CALCULATION SHEET Attachment #: A . a ANO 1 3 ANO 2 03 Grand Gul I 0 River Bend o Waterford 3 Component ID: 03-047 Report No.: 9OISIUT027 Material Tj (pe: CS Vessel Weld T.: NOTES: 2 2 

                  -5.5 The W2' Angles Used: 450 1v . 60° 700 S - . V. 00 L dimension on each side of the weld Is for Class 2 vessel volume.

This Is an approximate percent of the examination volume for which coverage was obtained.. 

                                                                                                                  'I 3      The plot shown is a representation of the actual profile and not to scale.

Li No Coverage Direction #1 Direction #2 i II I I I I I II Li No Coverage Direction #1 nNEEN Direction #2 Page 4 of 5 

     ~Ertey               EXAMINATION COVERAGE CALCULATION SHEET 70 Shear-wave Scan directions liii      No Coverage                      Direction #1                        Direction #2 All angle Cirr Scan Shear-wave Scan directions and O L-wave                -
                              \1l1W -                                                          '                 l~~~

F1 No Coverage Direction #3 lllllllll Direction #4 Required scan coverage: Weld -87.5%, Base material nozzle belt side -37.8%, Base material shell side 100% TOTAL EXAM VOLUME OBTAINED: 75.1% COMMENTS: Steam generator upper nozzle beltto uppershell weld. The primary limitation was on the required circumferential scans on the upper nozzle belt taper, base material. The cumulative coverage estimation includes the code required base metal coverage adjacent to the weld and the factor of multiple angles from multiple directions. Page 5 of 5

ENCLOSURE 4 CNRO-2003-00063 RELIEF REQUEST ANOI-ISI-004

ENTERGY OPERATIONS, INC. RELIEF REQUEST ANOI-ISI-004 ASME COMPONENTS Component/Number: Steam generator E32A upper head-to-tube sheet circumferential weld 03-001 ASME Code Class: I

References:

1. ASME Section Xi 1992 Edition, Table IWB-2500-1
2. ASME Section Xi 1980 Edition with the Winter 1981 Addenda
3. Letter from the NRC to Entergy Operations, Inc.,

Evaluation of Entergy Operations, Inc. Request for Authorization to Update Inservice Inspection Programs to the 1992 and Portions of the 1993 ASME Boiler and Pressure Vessel Code, Section XI for Arkansas Nuclear One, Units I and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3 (TAC Nos. M94472, M94471, M94454, M94473, and M94488), dated December 12, 1996

4. ASME Code Case N460 - Alternative Examination Coverage for Class I and 2 Welds, Section Xi, Division 1 Examination Category: B-B Item Numbers: B2.40 Unit / Inspection Arkansas Nuclear One Unit I - third (3d) 10-year interval Interval Applicability:

II. ASME CODE REQUIREMENT(S) ASME Section Xl, Table IWB-2500-1, Examination Category B-B, Item B2.40 requires essentially 100% volumetric examination of the pressure retaining welds. ASME Code Case N-460 allows a reduction in coverage for Class 1 and 2 welds due to interference or geometry as long as the overall coverage is greater than 90%. Ill. RELIEF REQUESTED Pursuant to 10 CFR 50.55a(g)(6)(i), Entergy Operations, Inc. (Entergy) requests relief from achieving the Code-required coverage (> 90%) when performing volumetric examinations of the subject weld. See information in Table 1. Page 1 of 5

Table I Limited B-B Examination Item ID Description Coverage (%) Reason for Limitation 03-001 Steam generator upper 71.0 Steam generator tube sheet head-to-tube sheet weld configuration and integral attachments and man-ways IV. BASIS FOR RELIEF During the ultrasonic examination of Weld 03-001, 100% coverage of the required examination volume could not be obtained due to the configuration of the steam generator. Specifically, effective volumetric examination is limited by the taper on the tube sheet side of the weld. Additionally, integral attachments and man-ways limited the coverage on the head side of the weld. Examination coverage calculation sheets provided in the attachment of this relief request show the head-to-tube sheet configuration, limitations, and the beam plots of the different examination angles used. The volume was scanned using 45°, 600, and 70° beam angles. Radiography is not practical because of the geometry of the component, which prevents proper placement of the film and exposure source. To perform the Code-required examination would require modifying and/or replacing the component. The examinations performed on Weld 03-001, in addition to the examination of other steam generator welds contained in the program, would detect generic degradation, if it existed, thereby demonstrating an acceptable level of integrity. V. PROPOSED ALTERNATIVE EXAMINATIONS Entergy has examined Weld 03-001 to the extent practical and will continue to perform pressure testing on the weld as required by the Code. VI. CONCLUSION 10 CFR 50.55a(g)(6)(i) states: The Commission will evaluate determinations under paragraph (g)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Due to design configuration, it is impractical to obtain greater than 90% coverage on Weld 03-001. To obtain the required coverage would necessitate modifying and/or replacing the component. Examinations performed on the subject weld, in addition to examinations of similar welds contained in the program, would detect generic degradation, if it existed, thereby demonstrating an acceptable level of integrity. Therefore, Entergy requests the NRC staff authorize the proposed alternative pursuant to 10 CFR 50.55a(g)(6)(i). Page 2 of 5 

             - ATTACHMENT RELIEF REQUEST ANOI -ISI-004 EXAMINATION COVERAGE CALCULATION SHEETS Page 3 of 5

IaEnei2y EX MI ATONCO ER GECA CU ATONSH E Attachment #: A a ANO1 l3 ANO 2 0 Grand GLf CI Rtver Bend l Waterford l Component ID: 03-001 Report No.: 991SIUr044 Material Type: CS w/clad Vessel Weld T: -90 NOTES: 

                      -      Angles Used: 450. 60° 700 S - 1% V. 0 L                                                 I 2      The 112T dimension on each side if the weld Is for Class 1 vessel volume.

2 This is an approximate percent of the examination volume for which coverage was obtained. 3 The plot shown Is a representation of the actual profile and not to scale. I i I. Fi No Coverage 5 Direction #1 E Direction #2 Page 4 of 5 pg/,fZqI 

   - Ente'Vgy            EXAMINATION COVERAGE CALCULATION SHEET No Coverage               V             Direction #1                    Direction #2 I       No Coverage               lllllllllllll Direction #3          lllllllll Direction #4 Required scan coverage:

Weld -81%, Base material head side -97%, Base material tube-sheet side -35% TOTAL EXAM VOLUME OBTAINED: 71.0% A COMMENTS: Upper head to tube-sheet weld approximately 426 inches Incircumference. Prmarily a single side examination from the upper head, however, some coverage was obtained sbanning from the taper on the t be-sheet side. The cumulative coverage estimation Includes the code required base metal coverage adjacent to Wb weld and the factor of multiple angles from multiple directions. The scan from the head was limited for approximately 47 Inches due to Integral attachments and the manways. Page 5 of 5 AJ ,gfA 7A'1f*2 .}}

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